May 22, 1991
CLA-2-84:S:N:N1:103 862904CATEGORY:CLASSIFICATIONTARIFF NO.:8428.90.0090; 8428.33.0000; 8428.39.0000; 8471.92.65
Mr. Ron Whitehead
Media Craft A/S
P.O. Box 451
3601 Kongsberg, NorwayRE: The tariff classification of a Tie-Line System from Norway
Dear Mr. Whitehead:
In an undated letter received by this office on May 1, 1991 you requested a tariff classification ruling.
The Tie-Line handling system is intended to automate the wholesale distribution of magazines by preparing magazine bundles for subsequent packing. It utilizes various interchangeable modules and customized software so that each system can be tailored to the exact requirements of a purchaser.
The system basically consists of a conveyor along which are arrayed manual or automatic order picking and statement printing equipment. The Tie-Line bundle conveyor consists of a continuously moving belt designed to transport magazine bundle carriers. A microprocessor, actuated by electric sensors and foot pedals, controls the sequence and movement of the bundles. The bundle carriers are specially designed to hold the proper number of each magazine title. They have an aluminum base and utilize plastic rods to prevent the magazines from spilling off. Each carrier is addressed with the name of a magazine retailer and a package number, allowing it to be identified by all stations along the conveyor line.
Any combination of manual or automatic order pickers can be arrayed alongside the bundle conveyor. Automatic order filling is performed by the MC100 counting and stacking machine. Incoming stacks of a particular magazine are placed on an inclined roller table for feeding into the MC100. Information such as the magazine's title, dimensions, and thickness is fed to the machine from the system computer terminal. The machine then picks the correct number of copies of the magazine and places them onto the correct retailer bundle carrier. Manual picking stations consist of 5 or 10 inclined roller conveyors within a rigid frame. They incorporate electric visual displays which indicate to the worker the quantity and title of the magazine to be picked, as well as the customer and package number. They also incorporate foot pedals which stop the bundle carriers so that the worker can place the order onto the carrier.
The Printronix package slip printer is used to print out a packing slip or shipping invoice for a particular retailer's order. The printer has the capability to print graphic images, such as bar codes or other symbols, based on data received from the control system. After the packing slip or invoice is printed and placed onto the bundle, the bundle is removed from the carrier and transported to a separate strapping machine while the empty carriers return to the initial picking site so that the cycle can begin again.
The entire system is operated and controlled by means of software which is designed for use with an IBM compatible personal computer. The software accepts new customer data, selects the route and order of picking, supervises the picking process, and controls the printing of invoices and data lists. Data communications and descriptions are customized for each client's system.
The applicable subheading for the Tie Line system, imported in a single shipment, will be 8428.90.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for other lifting, handling, loading or unloading machinery: other machinery: other. The rate of duty will be 2 percent ad valorem.
The applicable subheadings for the various modules, imported separately, are as follows:
For the Tie Line bundle conveyor and its accompanying bundle carriers classification will be in 8428.33.0000, HTS, which provides for belt type continuous-action conveyors;
For the manual picking roller tables classification will be in 8428.39.0000, HTS, which provides for other continuous-action conveyors; and For the MC100 counting and stacking machine classification will be in 8428.90.0090, HTS, which provides for other lifting, handling, loading or unloading machinery. The rate of duty for all of these provisions is 2 percent ad valorem.
The Printronix printer, imported separately, will be classifiable in the provision for automatic data processing machines and units thereof: input or output units: printer units in subheading 8471.92.65, HTS, and dutiable at the rate of 3.7 percent ad valorem.
Your inquiry does not provide enough information for us to provide a classification ruling on the software. Software, whether imported separately or together with the Tie Line system, is classifiable in heading 8524, which encompasses tapes and other recorded media. Lacking information as to the type and size of the media on which the software will be recorded, we are unable to provide you with a definite tariff classification number for this merchandise.
This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.
Sincerely,
Jean F. Maguire
Area Director